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noe Andrew Wise To: "Stephen Dille
vi . cc: andrew.wise¢ ing@,——~-GRO
4G (08/09/2006 09:36 cherylwoodward@ },mandy.talbot@ GRO I
ss rmorgan@__ "Tom Beezer”
atime <Tom.Beezer@
Subject: RE: Second draft witness statement of Andrew Wise: P.O -v- Castleton
Hi Stephen,
am happy with the amendments to para 22.
I have attached a copy of the page from our access database that shows the training details for Marine
Drive and their transfer.
id
Office Transfer Marine Dric
Regards
Andrew Wise
Training Manager
Post Office Ltd
Human Resources
Capstan house, Chandlers point, 35 Broadway, Salford Quays, Salford, M50 2PB
nee To: <andrew.wiseG,... <morgan@___.
ce: <carol.king€, <cheryl.woodward@
<mandy.talbot¢ “Tom Beezer"
GRO I
. <Tom.Beezer@ = SS . 4
7109/2006 19:22 Subject: RE: Second draft witness statement of Andrew Wise: P.O -v- Castleton
Dear Andrew,
Thanks for your email of 6 September.
I have made some further amendments in the light of your helpful
comments (new version attached). Are you happy in principle with the
amended statement? At para 22, page 6 you say you have a record of
Castleton being offered 4 days training from 14 to 17 July and also that
he had an on site trainer from 18 to 25 July. Please can you forward me
a copy?
Richard:
1. The main helpful amendment is para 28 page 7 which now describes the
remming in procedure in much more detail than we've had before.
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2. At para 23, page 6 we refer to the Horizon user Guide and Horizon
Operations Manual. These are very lengthy documents. Do you think we
should exhibit them to Andrew's statement?
Kind regards.
Stephen Dilley
-----Original Messaae-:
From: andrew.wiseG
J mandy. talbo'
rmorgané. 3 Tom Beezer
Subject: Second draft witness statement of Andrew Wise: P.O -v-
Castleton
Hi Stephen,
I have been through the statement again and answered your questions in
there, attached is the new version. I have answered your question below
underneath your question in red type.
(See attached file: STATEMENT Andrew Wise_1207758.DOC)
Regards
Andrew Wise
Training Manager
Post Office Ltd
Human Resources
Capstan house, Chandlers point, 35 Broadway, Salford Quays, Salford, M50
2PB
tel
<rmorgant.__
<Tom. Beezer!
Subject: Second draft
witness statement of Andrew Wise: P.O -v- Castleton
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Dear Andrew,
Thanks for your email of 23 August.
1. I attach a second draft of your statement, taking into account the
comments you made on the first draft. I have included some more
questions in bold italics. Please could you read the entire document
carefully and amend it until you are 100% happy with it then email the
amended version back to me.
2. Please could you contact personnel in Manchester and find out whether
they have any record of Mr Castleton or anyone else at the Marine Drive
branch (Fad code 2133377) being on holiday for the week ended 5 February
2005 (cash account week 45). The reason I ask is that the branch did
not make a loss that week, whereas the weeks either side of it the
branch made large losses. I have spoken to the HR teams in Salford and
there are no records to say that Mr Castleton (or anyone at Marine
Drive) requested leave on the 5th Feb 2004 (you put 4th feb 2005 in your
question, i assumed you meant 2004 but I had them check both years just
in case and nothing was showing). This does not mean he did not have
leave just that he never let the HR team know. Not sure if you have done
this or not but you could check the cash account for that week and see
who has signed it on the front. If Mr castleton was away there should be
someone else's signature on there.
I look forward to hearing from you as soon as possible and also to our
meeting on Monday with Counsel.
Kind regards.
Stephen Dilley
Solicitor
for and_on behalf of Bond Pearce LLP
From: andrew.wise§
Sent: 23 August 2006 1:
To: Stephen Dilley
Cc: andrew. wisel
mandy. talbot@
Subject: Re: First draft witness statement of Andrew Wise: P.O -v-
Castleton
Hi Stephen,
Please see answers to the questions you have asked below in red under
each question.
I have been through the statement and amended a couple of small things,
the main thing I altered was paragraph 20. This did not accurately
reflect at what point the email came from Cath Oglesby and when the
investigation was carried out by Sarah and myself.
Attached is a new copy of the statement with my alterations. Also I have
answered all of your questions that were in Bold Italics, I have
answered these in red after each question.
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(See attached file: STATEMENT V1_1198369.DOC)
If you require anything please let me know
Regards
Andrew Wise
Training Manager
Post Office Ltd
Human Resources
Capstan house, Chandlers point, 35 Broadway, Salford Quays, Salford, M50
2PB
“Stephen Dilley"
<Stephen.Dilley¢ GRO I To:
<andrew.wise€
‘om Beezer"
<Tom.Beezer( <rmorgan{
<mandy.talbot _ <cheryl.woodwardi
22/08/2006 12:35 Subject: First draft
witness statement of Andrew Wise: P.O ~v- Castleton
Dear Andrew,
Following our meeting on 14 June, I attach a (very) first draft of your
witness statement and exhibit. There are various questions for you in
bold italics within the statement and I'd be grateful if you could
answer them so that I can amend the statement accordingly. There are a
few additional
points:
1. Please do feel free to put it into your own words more. We need to
explain simply how the processes and systems work to a judge who will be
unfamiliar with it.
2. Are you content to give an overview of the calls made to NBSC
(paragraphs 25 to 112)? If not, please can you identify someone else at
NBSC who is and then we can ask them to give that part of the evidence.
I would be content to give an overview of these calls. Please note that
I probably dealt with very few of these calls (if any at all) and the
questions I have answered in the statement regarding the calls are a lot
of the time based on my interpretation (from experience) of what is
written in the call logs. Having not taken these calls myself, a lot of
the time I can only assume what the call is about and use my best
judgement.
3. Some of the NBSC call logs we have don't have a call reference.
Would you be able to locate the call references and insert these? I
would not be able to obtain these numbers. I think you may have to
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approach Dave Hulbert for this information.
4. When going through this draft, please can you amend as appropriate to
describe the systems that were in place at the material time (December
2003 to March 2004) if they were different to what is in place today. I
have made a note in the statement for you explaining that the weekly
balancing hand out I gave you is the procedure that is used now. Branch
Trading and Trading statements were not introduced until Sept 05. The
process on this handout was the same in Feb 03 apart from a few changes
where it mentions balancing monthly and trading statements. I have
amended these in the statement.
5. When the subpmr has to balance, does he check that the daily and
weekly figures match each other? They do not have to check this but it
is a practice that some SPMR will do. If everything is checked correct
on a daily basis then there is no one to repeat this.
I look forward to hearing from you as soon as possible.
Kind regards.
Stephen Dilley
Solicitor
for prd.anhebalf..of..Rand.Paarce..LUP.....
mF GRO
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Bond Pearce LLP is a Limited Liability Partnership registered in England
and Wales number 0C311430.
Registered Office: 3 Temple Quay, Temple Back East, Bristol, BS1 6DZ
A list of Members is available from our registered office. Any reference
to a Partner in relation to Bond Pearce LLP means a Member of Bond
Pearce LLP.
Bond Pearce LLP is regulated by the Law Society. (See attached file:
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any copies. Unauthorised use, dissemination, distribution, publication or
copying of this communication is prohibited.
Any files attached to this e-mail will have been checked by us with virus
detection software before transmission. You should carry out your own virus
checks before opening any attachment. Bond Pearce LLP accepts no liability for
any loss or damage which may be caused by software viruses.
Bond Pearce LLP is a Limited Liability Partnership registered in England and
Wales number 0C311430.
Registered Office: 3 Temple Quay, Temple Back East, Bristol, BS1 6DZ.
A list of Members is available from our registered office. Any reference to a
Partner in relation to Bond Pearce LLP means a Member of Bond Pearce LLP. Bond
Pearce LLP is regulated by the Law Society. STATEMENT_1209519.D
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